FEDERAL ELECTION COMMISSION

Washington, DC 20463

MEMORANDUM

TO:

FROM:

DATE:

SUBJECT:

The Commission 

Office of the Commission Secretary 

July 13, 2022

AO 2022-14 (Google LLC) 25 Individual Comments

Attached are 25 individual comments on AO 2022-14 (Google LLC).

Attachment 
From: Carl Staeblein

To: AO

Subject: concern about g-mail selling my e-mail info

Date: Tuesday, July 12, 2022 10:57:13 AM

I strongly object to google being allowed to sell my info to political groups ,do not allow google to market me

without permission which they do not have, Carl R. Staeblein
From: Ray

To: AO

Subject: election emails

Date: Sunday, July 10, 2022 3:18:46 PM

To whom it may concern:

Having just read a Business Insider article on this matter I felt the need to respond. As a Canadian living in Canada

who in 70 years has crossed the border once I have to express my concern about the potential change to election

email policy.

I have never supported any American political party I am as I said a Canadian I barely support political parties here.

I have never requested information from an American political party - I am after all, as I said a Canadian. To

summarize not once have I ever sought any political information from america. In spite of that track record and my

consistent efforts to not provide my email to any organization or company I do not have direct and ongoing contact

with I receive no less than an email a week and some weeks as many as three. Before your last national election it

was daily and and numerous in number. I have unsubscribed more times then the average Canadian says”eh” in a

year which is a lot. Consistently they are from republicans and the unsubscribe is both hard to find incredibly small.

Attempts to explain I am Canadian and don’t vote or donate money which is illegal for non residents ( I do watch

American news shows) I continue to get emails. If you change your policies clearly there will be those who seek

money from foreign sources and some people being limited in their intellect donate. Email addresses do not indicate

the country they go to as a result money could flow to political parties from nefarious sources.

In conclusion I am a Canadian fed up with being sent emails for money to help american politicians. As opting out

and unsubscribing seem to mean they simply sell the email list to a different fund raising group it would be helpful

and thoughtful if those of us who want can unsubscribe once and be free.

thank you and have a nice day

R. Cossette B. A. B. ed
From: Sandra Gill

To: AO

Cc: Sandra Gill

Subject: FEC Easing Google"s Gmail spam filters for political email

Date: Sunday, July 10, 2022 6:14:21 PM

Dear Gentlepeople:

I would like to comment on the request from Google to ease spam filters for political email. Simply put, NO!!

Political candidates and fundraisers have time and again proven that they are no better than other scammers (ex.,

male enhancement pills, Nigerian princes, Ukrainian brides, cheap ammo, etc.) at sending copious amounts of email

(which has little cost, unlike USPS mail) that is deceptive or baldface lies. As a simple example, fundraising emails

in the recent past from Trump to fight 'stolen election' did NOT fund any such events--NOR WAS THE ELECTION

STOLEN!!!

I am fully capable of finding out information about my local, state and national candidates from credible sources as

well as whether or not I wish to donate to a candidate or cause. I am already inundated with a horrific amount of

spam because Gmail has been so harvested with my email address. DO NOT allow Google Gmail to exclude

political email from spam filters. This is just another monetary boon to Google and detriment to me as a US voting

citizen. It serves no purpose except to further confuse and scam (hence 'scam filters!') potential voters.

Sincerely,

Sandra Gill

Thornton, Colorado

Adams County
From:

To: AO

Subject: Google spam re political email

Date: Sunday, July 10, 2022 5:34:14 PM

Good Morning,

You are clearly aware that you are allowing corporate profiteers to manipulate the system &

get unfair advantage by:

1. FAILING to adequate inform the public

2. FAILING to extend the time the public can respond.

In essence you are compromised & unethical in your conduct as it relates.

THE PEOPLE DESERVE TO KNOW ABOUT THIS & HAVE TIME TO WEIGH IN.

All other options is you complicit in google's attempt to target citizens!!!

Ms. Green
From: JakesLives1

To: AO

Subject: PLEASE.....SAY A BIG, LOUD "NO!" TO GOOGLE!

Date: Tuesday, July 12, 2022 3:02:17 AM

As a couple who relies on the internet, we urge you to strongly deny Google's request to let political committees

avoid spam filters.

This is important to us.....and to our friends and neighbors and children.

Many thanks you for your time......and for your wisdom.

Sally & Jake Schwartz
From: Dennis Jones

To: AO

Subject: Political email

Date: Sunday, July 10, 2022 3:59:45 PM

I have just finished reading a news article where Google is wanting for political entities to be allowed to send spam

emails.

I am totally against this proposal.

It is bad enough to have your postal mail box filled with spam political ads trashing each other. Now they want to

do the same for your email.

Do the right thing for once and deny this request.

Dennis Jones

Alabama resident
From: David Phipps

To: AO

Subject: Political Emails

Date: Sunday, July 10, 2022 3:34:32 PM

Dear Sir/Madam:

I am sending you my thoughts on the matter of unsolicited political emails. I vehemently oppose

allowing/permitting political emails to be sent to my email account!! It’s bad enough to be bombarded every

possible way already, to add another way to intrude upon my privacy!

Thank you for allowing my opinion to be heard.

Respectfully and Sincerely,

D. David Phipps Jr.
From: Lee Ann Davenport

To: AO

Subject: Political spam

Date: Sunday, July 10, 2022 2:55:11 PM

That would be a big fat no. We have a right not to be bombarded by the likes of Ted Cruz. He has already cost me

$20 in text fees.....
From: Gordon Andrews

To: AO

Subject: Political SPAM... just say no

Date: Sunday, July 10, 2022 3:38:32 PM

I hate SPAM of all types but getting email etc. from ANY politician or politician is even worse.

Honestly I don’t want any email from anyone which mention politics.. even my own family members .. some of my

own family members are now blocked in all ways because of their political comments.

Politicians do not have a “right” to send email to me unless I have given permission and can remove permission.

Nor do they have a right to share my email addresses.

Hoping the FEC gets the message. If not ... maybe everyone should start forwarding copies of all unwanted political

email to the fec. Imagine millionS of unwanted email ... daily.

Make politician send snail mail, costs thrn more and I can heat the house with it.

Gordon Andrews

Richmond Virginia

--

I support a woman’s right to choose. I believe no one should weaken that right.
From: Valerie M

To: AO

Subject: Unsolicited Political emails

Date: Monday, July 11, 2022 10:56:11 PM

Absolutely not!!! I do not want any blanket political emails sent to me!!!! No, no, no!!!!
1

From: Brett Schenker < >

Sent: Monday, July 11, 2022 2:26 PM

To: AO

Subject: Comment re: AO 2022-14

Dear FEC,

I am writing you today regarding Google’s request for an FEC opinion as to whether they can institute a pilot program

that bypasses their current spam filtering software for political candidates and campaigns. These messages would

instead be delivered directly into the user’s inbox at which point users would then be able to determine if the messages

are wanted or spam.

While Google is an entity that can do whatever it would like with Gmail, I must speak out not only against this program

but the narrative as a whole that there is “bias” in email filtering.

I am in a unique position to speak out and discuss this topic. I have worked in the political space for over 20 years, 18

years of which has been focused on the digital space beginning with then Senator John Kerry’s Presidential race and my

time directly in his Senate office. For the past 12 years, I have solely been focused on email deliverability in the political

and non‐profit space having worked for vendors such as Salsa Labs and NGP‐VAN, two of the largest in the space. In that

time, I have worked with hundreds of campaigns fixing their deliverability issues not just at Gmail but at other email

service providers.

With those years of experience, I can state that there is no “political bias” that Google’s decision would alleviate and

that all “deliverability issues” are due to the habits and decisions by the campaigns and their staff.

Below is a look at the inbox placement for 22 campaigns and political organizations from the past year using “panelist”

data. Some of these I have worked directly with and including to emphasize my point while others I have not. The data

includes their overall inbox rate from all email providers and the inbox rate at Gmail.

Party

Domain

Overall Inbox Rate

Gmail Inbox Rate

Democrat

dscc.org

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fdscc.org%2F&data=05%7C01%7Cao%40fec.gov%

7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C637931608490559

479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C

2000%7C%7C%7C&sdata=LHyKhZu1Pn%2FGH1kFsJaWYMLiNZUaXD4J6JnbeME2vlY%3D&reserved=0>  

93.50%

97.17%
2

Republican

rondesantis.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Frondesantis.com%2F&data=05%7C01%7Cao%40f

ec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C637931608

490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%

3D%7C2000%7C%7C%7C&sdata=tsdz%2BPIbFN6vHHVmT%2BvGKrJPl6QUewLT2w9ljCz%2F9%2FU%3D&reserved=0>  

91.80%

97.62%

Democrat

dnc.org

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fdnc.org%2F&data=05%7C01%7Cao%40fec.gov%

7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C637931608490559

479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C

2000%7C%7C%7C&sdata=A1otGvV8KubuoGIhq9Qsjl502o9Fga%2FQ%2BipzIiMC2%2FI%3D&reserved=0>  

91.50%

93.85%

Republican

email.rondesantis.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Femail.rondesantis.com%2F&data=05%7C01%7Ca

o%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C6379

31608490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6

Mn0%3D%7C2000%7C%7C%7C&sdata=DWdbyTo6%2FZFHTu05nubcRP4V3a8GCc350jM%2Ffu%2FWXPE%3D&reserved=

0>  

84.20%

79.76%

Democrat

dlcc.org

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fdlcc.org%2F&data=05%7C01%7Cao%40fec.gov%

7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C637931608490559

479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C

2000%7C%7C%7C&sdata=B%2Fd%2BPkLA0jwCvIMaOia6AOMRCAqqiO6uyG%2FJcIbfwVk%3D&reserved=0>  

82.80%

92.29%

Republican
3

mattgaetzforflorida.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fmattgaetzforflorida.com%2F&data=05%7C01%7

Cao%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C63

7931608490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXV

CI6Mn0%3D%7C2000%7C%7C%7C&sdata=sNlXC5ggZ%2FY4Pyn1rP8huu%2FVDq%2BMAj13%2Fr7sF5UC9tU%3D&reserv

ed=0>  

79.20%

89.31%

Democrat

ocasiocortez.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Focasiocortez.com%2F&data=05%7C01%7Cao%40

fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C63793160

8490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0

%3D%7C2000%7C%7C%7C&sdata=ql3VB4zpkBVA5Dj5JWTjyid14iCmZaxrGyTEkV4lLEA%3D&reserved=0>  

78.30%

89.72%

Republican

gaetz4usa.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fgaetz4usa.com%2F&data=05%7C01%7Cao%40fe

c.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C6379316084

90559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3

D%7C2000%7C%7C%7C&sdata=%2BOXMESyWNbm0Z7ZH0g9HaAOzJC3p8P1ONGRN7FHLjKI%3D&reserved=0>  

77.80%

100.00%

Democrat

chuckschumer.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fchuckschumer.com%2F&data=05%7C01%7Cao%

40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C637931

608490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6M

n0%3D%7C2000%7C%7C%7C&sdata=C9rXkZ2G3dTzp0MxXiN4rxBvmZDMNUxh54tBfIAOoB4%3D&reserved=0>  

74.90%

83.37%

Republican

campaigns.rnchq.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fcampaigns.rnchq.com%2F&data=05%7C01%7Ca

o%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C6379
4

31608490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6

Mn0%3D%7C2000%7C%7C%7C&sdata=C68Vrr1HJ4tOodRnpeRPcA%2BIIkL4zdPnCV5r%2BW0ai%2B8%3D&reserved=0>  

74.70%

75.37%

Republican

email.gregabbott.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Femail.gregabbott.com%2F&data=05%7C01%7Ca

o%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C6379

31608490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6

Mn0%3D%7C2000%7C%7C%7C&sdata=rGlDXcNz1qyfqnM%2FyiM3p5x%2Bc9v3aqj9gHEZktCJufk%3D&reserved=0>  

70.90%

97.67%

Democrat

dccc.org

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fdccc.org%2F&data=05%7C01%7Cao%40fec.gov%

7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C637931608490559

479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C

2000%7C%7C%7C&sdata=hv33DsYALp9JIiI1t7q%2BbcucY4R59Qwf1U2%2Fe%2BBxxM0%3D&reserved=0>  

68.40%

87.14%

Democrat

beatabbott.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fbeatabbott.com%2F&data=05%7C01%7Cao%40f

ec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C637931608

490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%

3D%7C2000%7C%7C%7C&sdata=6mQGybb9pURtrTOD4DZ%2BiIO%2FBKRdf%2FD6qriunFSubFA%3D&reserved=0>  

66.90%

94.37%

Republican

email.nrsc.org

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Femail.nrsc.org%2F&data=05%7C01%7Cao%40fec

.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C63793160849

0559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3

D%7C2000%7C%7C%7C&sdata=fBVIZXlqan4vvu4Ea5c3mhlZOicLZUOBBgP67Qh51WI%3D&reserved=0>  

64.50%
5

86.72%

Democrat

chriscoons.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fchriscoons.com%2F&data=05%7C01%7Cao%40fe

c.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C6379316084

90559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3

D%7C2000%7C%7C%7C&sdata=n4QEvCfrHafJXZvxpEg%2BB3u8Tn2DpkqrfrfGp5wxWPs%3D&reserved=0>  

64.10%

69.23%

Democrat

pelosiforcongress.org

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fpelosiforcongress.org%2F&data=05%7C01%7Cao

%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C63793

1608490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6

Mn0%3D%7C2000%7C%7C%7C&sdata=yszK2Y3ZnJeZlk9W1LUbLLCWknPPxd49uptBpNbN2EM%3D&reserved=0>  

53.70%

79.19%

Republican

email.donaldjtrump.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Femail.donaldjtrump.com%2F&data=05%7C01%7

Cao%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C63

7931608490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXV

CI6Mn0%3D%7C2000%7C%7C%7C&sdata=BZz2RZM4ktgYZIrECp8EGKd0aYdPNTUzTPbP1glnsGY%3D&reserved=0>  

52.60%

68.39%

Republican

win.donaldjtrump.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwin.donaldjtrump.com%2F&data=05%7C01%7Ca

o%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C6379

31608490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6

Mn0%3D%7C2000%7C%7C%7C&sdata=Ib9hQrWMa2SFUiXgwj1dNyJK%2Fx6hMqB5kk75LTfzuCU%3D&reserved=0>  

51.40%

70.55%

Republican
6

email.thenrcc.org

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Femail.thenrcc.org%2F&data=05%7C01%7Cao%4

0fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C6379316

08490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn

0%3D%7C2000%7C%7C%7C&sdata=hpNVFQF%2BTp1eLCgbyQaXK0QBzxXGFeoFlpZQWAI3e34%3D&reserved=0>  

37.70%

37.55%

Democrat

debbiestabenow.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fdebbiestabenow.com%2F&data=05%7C01%7Cao

%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C63793

1608490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6

Mn0%3D%7C2000%7C%7C%7C&sdata=pPC2%2BCBO7fMIZEnLHZfHiiB7q%2Fbei2sqp0HMhjS1XvA%3D&reserved=0>  

37.70%

15.61%

Democrat

stabenowforsenate.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fstabenowforsenate.com%2F&data=05%7C01%7

Cao%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C63

7931608490559479%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXV

CI6Mn0%3D%7C2000%7C%7C%7C&sdata=btszgIKztWEBBK3TsBHpe%2BZ8idEzg5WEFHl%2FOldw03Y%3D&reserved=0>  

36.00%

35.87%

Republican

cheneyforwyoming.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fcheneyforwyoming.com%2F&data=05%7C01%7C

ao%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C637

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12.20%

8.00%

  

Overall, we can see that the top ten has 5 campaigns labeled as Democrats and 5 are Republicans. When sorted for

Gmail, 6 of the top ten are Democrats and 4 are Republicans. However, the top three listed are Republicans with one

reported as perfect inbox placement at Gmail. The top inbox placement is for an organization connected to
7

Congressman Matt Gaetz, another one also connected with the Congressman is ranked #9 at Gmail. If there was a “bias”

by Gmail, these two organizations would have similar inbox placement and further down this short list. Instead, we see

that’s not the case and that inbox placement is much more complicated than some of those would have you believe. I

have no doubt that if we were to expand this data further to include all campaigns and political organizations, we would

find similar data indicating little bias. This data alone shows there’s no need for Gmail’s changes.

Today’s modern email filtering system relies heavily on the interaction of individuals to the messages they receive. Not

opening, marking as spam, deleting upon receiving the messages are all negative signs and the algorithm “learns” from

these interactions. It uses past actions to determine future placement. This encourages senders to send relevant email

to those who want to receive those messages. In the commercial world in the United States this is partially governed by

CAN‐SPAM, of which political campaigns and nonprofits are exempt.

The exemption of following that basic practice of “opting in” individuals is the cause of “struggles” some campaigns

experience when it comes to sending email. I can state as a fact that lists are traded between campaigns, taken by staff

to be used in future campaigns, provided by political parties to campaigns, and in many cases outright purchased.

Individuals do not “opt‐in” to such practices resulting in email addresses receiving messages from candidates and

organizations they don’t support and have never heard of. This is the very definition of spam. I myself receive dozens of

messages a day I haven’t signed up for, thankfully Gmail’s algorithm usually sends those to spam, so I am not inundated

by them.

The political infrastructure itself encourages these practices. Email sending platforms charge by the “emailable contact”

disincentivizing them from enforcing “opt‐in” requirements. They want large email lists on their platforms, so they make

more money. Consultants sell lists and get a cut of the sale, incentivizing themselves to be as loose with lists as possible.

Entire data brokers have sprung up whose entire role is to sell email addresses focusing on what’s a “valid address,” not

what’s wanted or opted in. Many of these data brokers and campaigns are in violation of “spam laws” in other countries

such as CASL and GDPR which are much more stringent in what is acceptable when it comes to email “opt‐in” as well as

data protection.

Google’s decision will only exacerbate this issue. It will encourage campaigns and organizations to purchase every Gmail

address they can find and email them as much as possible. Without the “penalty” of the algorithm, the already bad

habits will only be amplified. I am positive campaigns and organizations will be provided with even larger “starter” email

lists of Gmail addresses spamming Gmail users and inundating them with potentially hundreds of messages they did not

ask for and did not sign up for. There would be no incentive, as presented, to not do this. In fact, I have been asked

multiple times by candidates and campaigns about this exact strategy and what would stop them from purchasing

addresses and emailing them. My answer was “the algorithm would stop them.” It would also create a system of “haves

and have nots” when it comes to campaigns.

With this scenario, being part of Gmail’s program will become vital. Not being accepted or a part of it could cost

campaigns not just fundraising dollars but volunteers and get out the vote messaging. Every email not delivered is a

missed opportunity and Google would become the arbitrator of who is accepted and who is not which could be all the

difference in a successful campaign. During previous cycles, I studied email programs and their success or failure was an

indication of how well a candidate would do. The lower the open rates and higher the spam rates, the more likely they

would drop out or lose. Further, with parties controlling nomination processes, they could easily tip the scales by

providing “starter lists” with every Gmail address in a district to campaigns they favored. Combined with Gmail’s

program this creates a competitive edge exacerbating an already existing issue of the lack of party neutrality in races.

During my time at both Salsa and NGP‐VAN as well as an individual consultant, I have worked to fix email programs

increasing deliverability and inbox placement. This even includes advice to my friends working on email on the

Republican side. I couldn’t tell you the exact number of campaigns and political organizations I have worked with but it is

in the hundreds and most of the major organizations and campaigns. In my time I have seen their habits firsthand. One

organization purchased millions of addresses that caused them to be listed by Spamhaus, a major anti‐spam and anti‐

abuse network. I can say that every instance of issues I was called in “to fix” was due to the habits of the senders, not
8

“the algorithm”. By focusing on their “active” individuals who have shown they’ve wanted the email by opening and

clicking, these programs were turned around and had greater success by sending to fewer individuals. Yes, a smaller

email list can be more successful than large, bloated lists whose only function is sending volume to meet goals. I have

cut lists by up to 60% and the opens and clicks were greater not just in percentage but the number of individuals. I

understood the algorithm and designed targeting and a program that would be successful and proved to be. This is

exactly what commercial email senders do every day. Those that have not found success refuse to accept the reality of

how email works and instead feel the more they send, the better they’ll do. In fact, they’re hurting their program, and

Google’s decision to change Gmail would favor volume over quality, likely further deteriorating the trust in email,

political campaigns, and communication.

Google’s change to Gmail would also increase the shady and fraudulent campaigns and political email sent. With the

ability to send email so cheaply, nothing stops a campaign or organization from purchasing addresses and sending

messages attacking opponents from an ever‐rotating number of domains. If they’re registered with the FEC, they could

be a part of Gmail’s program. $10 nets a new domain and the Gmail list could be used over and over to send. It creates a

regulatory nightmare for the FEC as they would need to vet and govern an infinite number of organizations whose entire

purpose would be to send email to attack, raise money for unknown purposes, or outright commit fraud.

The latter is already an issue with an increase in questionable email practices. The FEC and FBI have taken some recent

action in fining and charging individuals for fraudulent emails putting campaigns on notice. However, this has not

stopped campaigns from sending emails that warn of “final notices” with hyperbolic statements to raise money from

individuals. Again, doing this on an even greater scale to Gmail’s users would surely raise even more money as it

“scares” individuals to comply with questionable senders that can change with every email blast. Studies show that this

type of email disproportionately receives money from seniors who are ”scared” into donating. This move would increase

the fraud the FEC is designed to stop. It is already a struggle to keep up with the ever‐changing landscape. This move by

Google for Gmail would make your job to stop fraud an impossible task.

I also have unique experience in that I worked in the United States Senate for Senator John Kerry. I know not just as a

sender but as a receiver of email from the public the United States Senate, House of Representatives, the US military,

and I’m sure the FEC itself uses email filtering software. I know messages sent to the Senate office were caught by the

filtering and some were missed. All systems are imperfect and I’m sure you yourselves have experienced this with work

email. I find it ironic that elected officials are condemning email filtering when they themselves use it daily. If they

themselves are calling for all political email to be delivered to inboxes, then they themselves should be prepared to do

the same for all email they receive.

I have experienced political email in numerous positions as a sender, receiver, and focused on deliverability. I am one of

the few in the world who can state that and what I touch upon is just a small sampling of why I think Google’s decision

to change Gmail’s algorithm is a mistake.

I’d be happy to discuss this further and would be happy to assist the Commission in any way possible.

  

Thanks,

Brett

‐‐  

Brett Schenker

Man of Many Things, Including
9

5B Consulting ‐ http://www.5bconsulting.com

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.5bconsulting.com%2F&data=05%7C01%7C

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=0>  

Graphic Policy ‐ http://www.graphicpolicy.com

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ao%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C637

931608490715705%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI

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Twitter ‐ http://twitter.com/bhschenker

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ao%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C0%7C1%7C637

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6Mn0%3D%7C2000%7C%7C%7C&sdata=jnMTqrvfurq0V8934ZJPEhe6uMT7dMtmaxzPNekC9bI%3D&reserved=0>  

LinkedIn ‐ http://www.linkedin.com/in/brettschenker

<https://gcc02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.linkedin.com%2Fin%2Fbrettschenker&data

=05%7C01%7Cao%40fec.gov%7C72bf7b42979440e0945a08da636b0023%7Cee91fa706c9d45e0bb084a355de91010%7C

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haWwiLCJXVCI6Mn0%3D%7C2000%7C%7C%7C&sdata=yCBA8v0KjEdNCTIBBmEpNsXjTUBzdWmhAD5FywlIf1k%3D&rese

rved=0>  
1

From: Rolf < >

Sent: Saturday, July 9, 2022 8:51 PM

To: AO

Subject: NO to Google’s request

NO to Google’s request to do a pilot program where campaign ads go to people's inboxes and not through their spam

filters
1

From: Jeff Kleist < >

Sent: Saturday, July 9, 2022 5:19 PM

To: AO

Subject: Google plan to bypass spam filters with political ads 

I cannot object enough to any plans to bypass spam filters with political ads

Political communications need to be opt in only. No door knocks, no phone calls, no smoke signals. We need a do not cal

list that slo blocks online advertising.  

The endless harassment every fall needs to stop. And you need to forbid third parties access to these lists as well. No

contact, in any form, by anyone isn’t a hard concept. It’s harassment plain and simple.  
1

From: Carmen Bocanegra >

Sent: Saturday, July 9, 2022 4:43 PM

To: AO

Subject: NO to Google campaign ad pilot program

NO to Google’s request to do a pilot program where campaign ads can go straight to peoples inboxes and bypass their

spam filters. No.

Carmen Bocanegra

NC
From: Peter Hurley

To: AO

Subject: Comment to Google"s request for opinion on pilot program

Date: Saturday, July 9, 2022 3:15:13 PM

Dear FEC,

I am writing to oppose approval of Google's pilot program to allow campaign emails to bypass spam filters.

The large majority of political fundraising emails are, in fact, unsolicited spam. Fundraising lists are shared among

political organizations and bought and sold openly between them. Signing up with one organization can mean an

endless influx of emails from tens or hundreds of different campaigns and PACs who have purchased or shared

email lists among each other. Google touts that it requires one-click unsubscribe, however this does not address the

issue of trading user information, and the fact that often users would be seeing spam emails from campaigns with

which they have never had any interaction.

One click unsubscribe only works if users ignore best security practices. The best security practice is to never click

on a link from an email whose sender you do not recognize. Since almost all campaign emails are built off of

purchased or shared lists, users will not recognize those emails as from a source they have interacted with, and

should not click any links, including unsubscribe links.

This proposal will lead to a large degradation of email user experience, and requires email users to ignore proper

security practices to stop it. Unwanted and unsolicited advertisements from campaigns should be put in the folder

where they belong: spam.

Regards,

Peter Hurley

New York, NY
From: Ginny Pope

To: AO

Subject: Google Pilot re Political Spam

Date: Saturday, July 9, 2022 3:04:54 PM

Dear FEC,

Please do not allow this to proceed. Spam filters are increasingly needed to ensure we don’t get inundated with

email we don’t want and never agreed to. I don’t mind checking my Spam folder now and again for email I DO

want to see.

Best regards

Virginia Pope
From: Livia

To: AO

Subject: Google request for pilot program regarding political email

Date: Saturday, July 9, 2022 4:32:14 PM

No. Just no. The FCC should not stand by in allowing google to manipulate what email goes directly to the

consumer any more than it already does. While it is a popular platform for email people prefer government to err on

the side of the consumer, not the company. There is ample opportunity for this yet it seems the FCC and others err

toward the company. Please, in this instance do not grant Google this power.

I already get unwanted political texts as someone put my phone number down as a contact for elections taking place

in a state I do not reside in. I treat these texts as spam and try to get my number off the list but, as I am sure you

have experienced, once on a list (US mail, phone, text, or email) getting off is a challenge to say the least.

Thank you,

Livia Lewin
From: Catherine Johnson

To: AO

Subject: NO to Google campaign ad pilot program.

Date: Saturday, July 9, 2022 2:52:51 PM

NO to Google's request to do a pilot program where campaign ads go to people's inboxes and not through their spam

filters.

Catherine Johnson

California
From: Rachel Anderson

To: AO

Subject: Comment: AO 2022-14 Google pilot program

Date: Saturday, July 9, 2022 2:27:56 PM

Dear Federal Election Commission

I write in opposition to the pilot program proposed by a technology

corporation to enable their email product to bypass spam filters for

email from authorized candidate committees, political party

committees, and leadership political action committees.

Email is a crucial communication vehicle through which I conduct

business, maintain personal and family relationships, and communicate

with my children's teachers and coaches. In order for email to remain

functional, I must be able to filter out content that I have not

requested or that is not urgent to my family's daily needs. I would

like to retain the choice to direct political email to a designated

'spam' folder where I can review it at my own discretion. This should

simply be the case as a matter of choice but here are several

additional reasons why the FEC should reject this program:

1) Candidate committees, party committees are notoriously unresponsive

to requests to desist from sending email. I have sought to remove

myself from certain lists multiple times and to absolutely no avail.

2) Allowing certain political emailers to circumvent spam filters

would have the perverse effect of discouraging political participation

and political association. One reason I receive political email is

that I have actively participated in the democratic process as a

campaign volunteer and small dollar donor to candidates that I

support. However, if it were the case that doing small citizen acts

such as door to door canvassing were to routinely expose me to masses

of unwanted email, then I will be more reluctant to undertake these

activities.

3) The avalanche of unwanted email and texts from marketers and

political campaigns is having a negative effect on the nation's social

capital. I and many others find it harder and harder to connect with

friends, family, school and small local organizations over email

because of the vast quantity of spam received in a day. Friends,

family, schools, community organizations do not have the budgets to

spend on massive email programs and, thus, have their voices drowned

out by organizations that do have the resources. The proposed pilot

program would only worsen this situation.

Thank you for considering these comments. I urge the FEC to reject the

proposed email pilot program and enable citizens to exercise choice in

selecting the emails they wish to receive in their inboxes.

Sincerely,

Rachel Anderson
From: Lizz Horvath

To: AO

Subject: No to Google campaign pilot program

Date: Saturday, July 9, 2022 3:50:53 PM

NO to Google's request to do a pilot program where campaign ads go to people's inboxes and not through their spam

filters.

Concerned voter,

Lizz Horvath

Georgia
From: loripuck17

To: AO

Subject: Google political email request - Say NO!!

Date: Tuesday, July 12, 2022 2:24:58 PM

Dear FEC,

Google is asking FEC for permission to start allowing email sent to Gmail users from political

candidates and parties (both during and outside campaigning season) to bypass Google’s spam

filters and be delivered directly into users’ inboxes. Google asserts that users themselves will

be able to stop these emails by “one-click unsubscribe” banners attached to the messages.

Given the number of political candidates and party demands for support of one type or another

year-in/year-out and the virtually zero cost of sending email messages, I can see that this loss

of initial filtering will lead to a very large number of unwanted emails being delivered to

1.5billion Gmail users’ inboxes that will have to be individually opted-out of. I also have

noticed in the majority of email messages I have received over the years with “one-click

unsubscribe” options that these banners are usually hard to find and using them does not

always lead to a user being unsubscribed. Googles opinion of how easy it will be for their

users to filter out these messages seems quite unrealistic.

I am also concerned that providing this option to political candidates and parties to solicit

funds from users will increase the already vast amount of money scamming emails that the

general public is subjected to. This action by Google is probably their way of reacting to

charges of partisan favoritism in their filtering but is it really a good idea to make the general

public bear the brunt of the massive amount of political and financial scam spamming that will

occur as a result of this action?

Please deny Google’s request. Anyone interested in receiving emails from political candidates

and parties already has easy ways to receive those messages/solicitations via signing up for

such on the websites of these individuals and organizations or requesting it from contact

information provided in their mailed flyers or TV/internet ads.

Thank-you for your consideration,

Lorraine Puckhaber (a concerned US citizen resident in Texas)
From: Suzanne Abbott

To: AO

Subject: NO to Google campaign ad pilot program

Date: Saturday, July 9, 2022 3:54:43 PM

NO to Google’s request for a pilot program where campaign ads are sent directly to people’s inboxes and not

through their spam filters.

-SCA

Sent from my iPhone
1

From: Michele M. Algreen < >

Sent: Tuesday, July 12, 2022 5:33 PM

To: AO

Subject: NO MORE POLITICAL SPAM | Google's Political Spam Request

To Whom it May Concern:

I am writing with regard to Google’s request to allow political spam emails to avoid their spam filters. As someone who

gets more than two dozen spam emails a day from a single candidate for governor in Georgia (I live in Arizona), I

respectfully request that you reject Google’s request and instead require more strict laws surrounding political spam.

I have never lived in Georgia, I have never donated to Marcus Flowers campaign for governor, and I have never

subscribed to his newsletter. Yet... I get dozens of emails every single day from his campaign. I have tried clicking the

‘unsubscribe’ link in a couple of the earlier emails and I have also written (several times) directly to the campaign email

address requesting that my email be removed from their list. My requests have been completely ignored and I continue

to get dozens of emails per day.

I am so beyond tired of these emails and there seems to be no way to stop them so they continue appearing in my spam

and/or trash folders every single day. I implore you to please reject Google’s request to allow more political spam to

inundate user inboxes. Additionally, I would like to implore you to please implement new rules that REQUIRE all political

campaigns to immediately honor requests for removal from their lists and also allow recipients a way to report

campaigns that do not honor requests to be removed.

Please, no more political spam!

Thank you for your time and efforts.

Sincerely,

Michele M. Algreen
1

From: S G < >

Sent: Tuesday, July 12, 2022 5:37 PM

To: AO

Subject: Comment for Google’s Request for Opinion on Pilot Program

To say that that I have a low opinion of this idea would be understatement taken to an extreme.    

Unsolicited political emails are the same as unsolicited porn emails, which are the same as unsolicited viagra emails, and

so forth:   Invasive, offensive wastes of the most valuable resource any human has:  their time.   

The government already failed to protect us from political spam via phone. Don't fail again.  
1

From: Max B < >

Sent: Tuesday, July 12, 2022 5:38 PM

To: AO

Subject: Don't exempt political emails from spam

Hi, 

Please reject this exemption. I will quit email altogether if unblockable political emails enter my inbox 

and turn the experience into social media. My mental health is at stake. 

Thanks, 

Max